It's rare that the New York Times and Wall Street Journal agree so wholeheartedly on things, but this past week has seen both issue calls for wireless innovation across the United States. The New York Times issued a pro-municipal wireless editorial that, among other things, states:

Broadband service is no longer a luxury. It has become a basic part of the infrastructure of education and democracy. EarthLink should fulfill the commitments it made. Even in these tough economic times, cities should keep pushing municipal Wi-Fi and looking for partners and plans that can make it a reality.

Lee Gomes from the Wall Street Journal issued a pro-White Space Device column that focuses on the successes and potential uses of these new technologies:

The white-space proposal has been in the news in recent weeks because of its strong backing by Microsoft and Google, among others. White space, they say, could help create a "Wi-Fi on steroids," with faster connection speeds running over longer distances than are possible now in the hot spots common in homes and coffee shops. As for interference with TV broadcasts -- or with wireless microphones, which use this same spectrum -- that can be easily handled. Before transmitting any data, a white-space networking device would "listen" to detect if a frequency is in use. A version of this "smart sensing" is already widely and successfully deployed by the U.S. military.

Here are the full stories:

Read more...

I'm sure that the NAB will soon be releasing a flurry of PR decrying the failure of a white space device during FCC testing. Which device, you may ask? Why, the Microsoft one, of course. And which device failed miserably during the first round of FCC testing? Why, the Microsoft one, of course. But didn't a white space device suffer a power failure last month -- which one was that? Why, the Microsoft one, of course.

So what's the National Association of Broadcasters going to go to town on -- declaring that the technology simply won't work based on the failure of a single company's device? Why, yes, you guessed it...

So why is the National Association of Broadcasters spending so much time and energy filling the press with the continuing failure of Microsoft's device? Probably because they're scared as hell that someone might otherwise point out that the DARPA XG Project has already proofed out the viability of white space device technology.

"Hold on a second," you might ask, "white space device technology has already been proofed out and deployed by the military?!?" Indeed! In fact, on September 18, 2006 Shared Spectrum publicly announced the successful testing of DARPA XG technology for battlefield warfare. Assuming for a second that physics works the same for both military and consumer products, if white space device technology works for battlefield warfare, I'm of the opinion that it's going to work in my living room as well. In fact, DARPA XG technology was successfully tested in civilian situations at DYSPAN in Ireland on April 16-20, 2007.

So why is this even an issue? Because physics, reality, precedent, and data are coming up against a monstrously large PR and FUD campaign by one of the most powerful lobbies in Washington, DC -- the National Association of Broadcasters. Which begs the question, who sucks even more than Microsoft?

A lot of folks have been asking me for my take on the recent Google ex parte filing at the FCC.

Google put in its ex parte on Friday, March 21, 2008. The final draft of the document does reflect some of the input that the New America Foundation provided, but still offers proposals that are particularly discouraging for ad-hoc (decentralized networking).

Here's a brief synopsis:

1. Google (and 30+ other major corporations) are developing an open stack mobile system (a.k.a., the Android phone) as a part of the Open Handset Alliance and want to use the white space as a medium for these new technologies.

2. Google is offering, "to provide, at no cost to third parties, the technical support necessary to make these plans happen; this could include intellectual property and reference designs for underlying technologies, open geo-databases maintained by Google, and other supporting infrastructure."

3. Google is backing Motorola's plan for "a combination of geo-location (to protect broadcast TV) and beacons (to protect wireless microphones)."

4. Google is proposing a safe harbor on channels 36-38 for wireless microphones.

5. Google states that "the combination of geo-location, beacons, and 'safe harbors' is more than sufficient to ensure the protection of all licensed uses."

6. Google reiterates that the technology has already been proofed out in the Darpa XG project and that DARPA XG systems are now in use by the military (the field deployment was new information): "widely used 802.11a-based WiFi currently supports spectrum sensing to protect military radar from interference. Moreover, the Defense Advanced Research Projects Agency (DARPA) neXt Generation (XG) program has graduated from lab experiments to field use of the technology. Both examples represent an important existence proof for the viability of spectrum sensing, where the risks of failure inarguably are far greater than those potentially posed to broadcast TV and wireless microphones."

7. Google asks for the creation of a Further Notice of Proposed Rulemaking to explore the geolocational/beacon solution.

You can read the March 21, 2008 Google ex parte here.

Congressman Nadler's recent Op-Ed in the New York Times, "We Interrupt This Broadcast" is full of misinformation and verifiable incorrect assertions. Folks like former FCC Senior Counsel, Kenneth Carter, and Matthew Lasar over at ars technica have already taken the piece to task for reading like a spin project of the National Association of Broadcasters. Since I've had a bit more time to address Congressman Nadler's Op-Ed rather than just focus on the propaganda aspects of the piece, I thought I'd provide some primary sourcing to directly refute the main points of his article.

Congressman Nadler claims, "White spaces are the intervals between television channel frequencies to ensure that TV reception is not interrupted by other signals" -- ignoring the white spaces that exist in vast swaths of the country currently underserved by TV broadcasters that have nothing to do with preventing adjacent channel interference. Talk to folks living in rural America and ask them how many TV channels they get on their rabbit ears and compare that with the channels that anyone living in the top metro markets gets. Then do the math
-- are their more channels in New York City than in Greenup, Illinois? If yes, then you're left with an inconvenient truth -- one can clearly put more TV channels in rural areas without causing interference.

But even more than that -- the spacing between TV channels are meant to prevent interference of stations who were using the best analog equipment available (as of several decades ago) and broadcasting at tens of thousands of Watts of power.

Which begs the question, "Is it possible that the spectrum spacing needed to prevent interference by 30-year old technology operating at 50,000 Watts might be more than todays cutting edge digital technology operating at, say, 200 Milliwatts?" If you suspect that answer might be "yes" -- congratulation, not only are you correct, but my good friend, Physics, is here to back you up.

Congressman Nadler goes on to state, "The usefulness of these white spaces is about to be compromised by a proposal before the Federal Communications Commission by some of the nation’s largest technology companies. Microsoft, Google and others are asking permission to use white spaces — free of charge..."

This sin of omission is particularly egregious -- Google got involved years after public interest groups were working to open up the public airwaves to the general public. Don't believe me? Check for yourself -- point your browser to the FCC's Filed Comments search form: put "04-186" in as the proceeding number (box 1) and either "Google" in the "Filed on Behalf of" line (box 4) then click the "Retrieve Document List" button. What you'll see is every document pertaining to the FCC's white space proceedings filed by these organization.

For Google, it looks like their first involvement was in 2007. Microsoft, on the other hand, got involved in 2004 (the year the proceeding actually began).
But what about the "others" that Congressman Nadler so quickly mentions?
Probably some other major corporations, right?

One of them is the New America Foundation, which I work for -- a public interest think tank. But there's also the Media Access Project, a public interest law firm; Consumers' Union, who fight for consumers' rights and publish "Consumer Reports"; Educause, a national coalition of institutions of higher education; Common Cause, one of the nation's largest citizen advocacy organizations; the Office of Communication of the United Church of Christ, which works to "assure a just and equitable media that gives meaningful voice to diverse peoples, cultures and ideas"; the Consumer Federation of America, a consumers rights group with "a combined membership exceeding 50 million people"; the National Hispanic Media Coalition, which advocates for "media and telecommunications policies that benefit the Latino community; as well as dozens of additional community groups, non-profit organizations, and consumer rights coalitions. Why does Congressman Nadler marginalize this massive public interest coalition, ignore the years of work that these groups have put into supporting White Space Devices, and dismiss their existence as "others"?

And of course we want consumers to be able to access white space free of charge
-- this is exactly why the National Association of Broadcasters, wireless microphone manufacturers, and their allies don't want white space devices to exist. The reason why such a large coalition of public interest and consumer rights organizations support white space devices is because they'll save us money, spur innovation of myriad new consumer products, and (through that
competition) lower the costs of everything from broadband (and media) services to next-generation wireless microphones.

Congressman Nadler follows this up with an entirely paradoxical two sentences, "These devices could disrupt the new digital TV signals that government and industry have spent so much time and money to promote. In my district, which includes New York’s theater district, performers use wireless microphones on these 'unused' frequencies, as do news crews conducting live interviews on the street." Pause for a moment to consider what the Congressman is saying -- these devices could cause disruption, but we've been using them for years. He follows this illogic up by claiming, "in rural areas, white spaces are often used for broadband access" -- where is he getting his information. The first 700MHz radios were only created this past fall -- Ubiquity claims to have built the first ones. As the press report clearly states, "No word on pricing or street date, mostly -- we suspect
-- due to the fact that the frequency it operates on has yet to be made available."

When Congressman Nadler states, "unlicensed devices, like wireless laptops and remote-controlled toys, operating in the white spaces will probably cause havoc to TV viewers, theater goers and sports fans" he must be betting on the fact that physics works differently in the equipment folks in his district use than for the rest of us. And then he descends into the FUD -- TVs will stop working, the low-income and elderly will be harmed, emergency services will be interrupted, productions of Cats destroyed, NFL quarterbacks sacked -- for those of us in the know, these claims are about as ridiculously as claiming that white space devices are going to cause meteor strikes and bubonic plague.

Congressman Nadler continues on his litany of misleading information stating, "last year, when the F.C.C. tested the 'sensing' mechanism of some of these unlicensed devices, none of them detected broadcast and wireless signals consistently enough to avoid interfering with them." Let's take a look at the actual data from the FCC's own report. If a picture's worth a thousand words, let me greatly shorten my article and show you two. The first, I'll call the "Nadler Worldview" -- it gives you half the picture (in this case, Figure 3-4, which is located on page 14 of this report).

As you can see, as long as blinker ourselves and only look at half the data, Nadler is correct... the problem arises when we look at the full picture. But, at -115 dBm, the prototype white space device worked perfectly, correctly sensing broadcasts 100% of the time:

Meanwhile, for those claiming that these technologies are infeasible, I'd recommend taking a look at the Darpa XG project which, among other goals, is "developing technology and system concepts for military radios to dynamically access spectrum in order to establish and maintain communications...access 10 times more spectrum with near-zero setup time; simplify RF spectrum planning, management and coordination; and automatically de-conflict operational spectrum usage. XG technology assesses the spectrum environment and dynamically uses spectrum across frequency, space and time." You might also want to read the Darpa XG press release from 2006 where successful field-testing of the technologies were conducted. For those that would like to get down into the weeds, here's a link to a declassified overview of the Darpa XG project. I would like to see these technologies developed for civilian use. Given the previously successful testing of XG radios, assuming physics doesn't differ, it's clear that white space device technology is feasible for civilian use as well.

You don't hit a man while he's down, so I'm not going to end my post by going after Congressman Nadler, but rather with an offer of help. Personally, I think the Congressman has been had -- either by industry folks who sold him a bill of goods or advisors who didn't do adequate due diligence. In fact, a whole lot of folks have been had -- the NAB and its allies are spending millions of dollars to create fear, uncertainty, and doubt about white space devices (and a few million buys a good amount of confusion).

So my offer is this: Congressman Nadler, give me a call, I'm more than happy to sit down with you and your staff, walk you through any questions or concerns you might have, and get you primary sourcing so you can check my assertions for yourself. I've been speaking with a number of Broadway theater groups and found they they two have been sold the same bill of goods -- I'd like to take the time to clear the air, cut through the FUD, and get you the information you need.

In addition, anyone who wants to learn more can download New America Foundation's Policy Backgrounder: Unlicensed White Space Devices and Myth of Interference that I co-authored with my colleague, Michael Calabrese (executive summary is online here).

"Smart" wireless devices can use the unassigned frequencies between broadcast TV channels to offer wireless broadband and other innovative services. A rulemaking is pending at the FCC (docket 04-186) to permit unlicensed access to this currently wasted spectrum, subject to technical requirements that will protect television reception from interference. Access to the vacant TV channels in each market has been the subject of intense lobbying, yet far too many of the arguments against "white space" devices rely upon misinformation about the technologies and the FCC process that will prevent harmful interference to DTV reception and other incumbent services.

This policy backgrounder offers a summary analysis, and is an effort to help policymakers strike the appropriate balance between protecting existing services from interference while making the benefits of mobile broadband services available and affordable for all consumers. It provides policymakers with:

1. a brief historical background to the current FCC proceedings;
2. a description of White Space Device (WSD) technologies;
3. a “Myths vs. Facts” section addressing the key concerns raised about WSDs;
4. an overview of the public benefits of WSDs; and
5. a concise summary of where we are in the multi-phase process of adopting WSD technologies for consumer use.

For the full document, please click here.